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Contact Us Policy 

 

 

 

 

 

 

 

 

 

a) Who processes your personal data:
 
XOEAN LLC.,

e-mail address: customerprivacy@xoean.com ("XOEAN"), is the company which, as Data Controller, collects and processes your personal data.

b) How we collect and why we process your data:

The data you provide to us by filling in the electronic form available in the section “Contact us” (title, name, surname, date of birth, e-mail address, mobile phone number, country/region of residence) or by using the contact services through e-mail or phone available on www.xoean.com will be processed in order to:
 
1. reply to and handle your request or claim.
 
The legal basis for the processing of your data will be the management of your requests (for EU residents, this is pursuant to Article 6, paragraph 1, letter b) of Regulation (EU) 679/2016 General Data Protection Regulation (the “Regulation”).

c) Your consent:
 
Your consent is not required in order to manage your request or claim pursuant to art. 6, paragraph 1, letter b) of the Regulation.
 
d)  Which data are processed and which ones are mandatory
 
For the purposes indicated above, XOEAN shall process the following categories of personal data:

  • Personal details (title, name, surname, date of birth); 

  • Contact details (Country/Region of residence, e-mail address, mobile telephone number);

  • Data related to the purchases you made, only in case the request relates to the purchases you made (boutique where you made the purchase, number, type and price of the purchased products).

We ask you to provide all the data requested as “mandatory” (e.g. title, name, surname, e-mail address, mobile telephone number, country/region of residence) as needed in order to better manage your request; in case of missing or incomplete filling in of such data, we could not be able to process your request.
 
e) How do we process your data:
 
Your data will be processed with and without the aid of electronic tools and stored on servers located in America. 
Your data will be processed pursuant to the applicable laws.  We use reasonable and appropriate security measures to ensure the confidentiality of personal data and the prevention of unauthorized disclosure, use, alteration or deletion thereof. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
 
f) How long do we store your data:
 
In general, personal data will be retained for no longer than is necessary for the purposes of duly handle your request.

g) By whom your data are processed:
 
For the purposes of managing your request (within the limits of their respective tasks) data will come to knowledge of the persons in charge of the processing at XOEAN CRM Department, Retail Department and other Departments in charge of handling your requests, your purchase and relevant services; your data will also be processed by companies that provide us with services[1] to manage our web site, the clients services, the purchases or that carry out related services on our behalf, as well as to our commercial partners.

h) Your data is transferred outside the European Union:
 

To allow us to provide you with a tailored service also in the event of purchases made at XOEAN stores abroad, your personal data may be transferred to the extra-EU countries/regions where XOEAN stores are located, and/or in countries/regions within or outside of the European Union where our commercial partners are established.
 
The transfer of your data will take place in full compliance with the safeguards, measures and rights as provided for by the data protections laws [2]. By simple request to be made at the contacts indicated in paragraph i), EU residents will receive more information on the transfer of your data and on the safeguards provided for their protection.
 
i) Your rights:
 
By sending an email to XOEAN CRM Department, e-mail customerprivacy@xoean.com, XOEAN LLC.,  EU residents may exercise at any time their rights[3]provided for by Articles from 15 to 22 of the Regulation, such as access which data we are processing, with which methods and for what purposes we process them, rectify the data you provided to us or delete them, ask us to restrict the processing of your data, request to receive or ask for the transmission of your data to another data controller.

In particular, EU residents have the right to withdraw at any time the consents provided to the processing (if any) and to object to the processing of your personal data especially for marketing purposes and/or for the analysis of your preference.
 

j) Who you can contact to lodge a complaint:
 
We remind EU residents that, should you consider the processing of your data infringes the Regulation, you may in any event lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it), or, if different, the Data Protection Authority of the Member State of your habitual residence, place of work or place of the alleged infringement.
 
k) Data Protection Officer (DPO):
 
You can contact the Data Protection Officer appointed by XOEAN at the e-mail address dpo@xoean.com.
 
Footnotes
 
[1] Your data may become to knowledge, as external Data Processors, of the following recipients:

i.    retail companies which manage XOEAN stores in Italy and abroad (if you have made purchases in our stores);
ii.    companies that are commercial partners of XOEAN;
iii.   companies which carry out the analysis of your purchases on our behalf;
iv.   companies responsible for managing XOEAN "Customer Service" on our behalf;
v.    companies entrusted with the management of our website and the related databases;
vi.   companies that deal with the management and technical maintenance of the CRM system.

 
The names of all the external Data Processors can be requested via email to customerprivacy@xoean.com.
 
[2] Pursuant to the applicable legislation, we do not need your specific consent to transfer your data to third countries/regions since the transfer is made on the basis of appropriate safeguards pursuant to articles 46 and 47 of the Regulation, such as the adoption of the standard data protection contractual clauses adopted by the EU Commission as it happens in the relationships with the Retail companies that manage the XOEAN stores in the world.
 
The transfer of your data to any additional third countries/regions, if necessary, will take place in full compliance with the safeguards, measures and rights as provided for by the Regulation. By simple request to be made to the contacts indicated in paragraph i), EU residents will receive more information on the transfer of your data and on the safeguards provided for their protection as well as on the means to obtain a copy of the data or the place where they were made available.
 
[3] The articles from 15 to 22 of the Regulation recognize specific rights including:

  • obtaining confirmation as to whether or not personal data concerning you is being processed;

  • obtaining access to your personal data and to the information set out in Article 15 of the Regulation;

  • obtaining the rectification of the inaccurate personal data that concern you without undue delay or the supplementing of incomplete personal data;

  • obtaining the erasure of the personal data that concern you without undue delay;

  • obtaining the restriction of processing the personal data that concern you;

  • being informed of any rectifications or erasures or restrictions of processing in relation to the personal data that concern you;

  • receiving in a structured, commonly used and machine-readable format the personal data that concern you;

  • objecting at any time, on grounds associated with your specific situation, to the processing of the personal data that concern you.

In particular, you have the right to withdraw at any time the consents provided to the processing (if any) and to object to our market analysis activities.
 

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